Model 231

The company ZHERMACK S.p.A. is sensible to the need to ensure conditions of fairness and transparency in business and corporate activities, to preserve its position and image, the expectations of its shareholders and the job of its employees. ZHERMACK S.p.A. has considered in accordance with its policy the implementation of the organisation, management and control model established by Legislative Decree 231/2001, which has introduced the rule of administrative responsibility of the company. Said regulation establishes, in compliance with OECD guidelines for multinationals, that companies can be deemed as responsible and, subsequently, suffer economic sanctions for certain offences that are either committed or attempted in the interest or to the advantage of the company itself by its directors or employees. To rule out the aforementioned responsibility, companies must adopt organisation, management and control models that can prevent said offences, models whose principles can be found in the code of conduct (guidelines) drafted by Confindustria. Therefore, the model can be defined as a complex organ of principles, rules, provisions, organisational patterns and related duties and responsibilities that are functional towards the implementation and diligent management of a control and monitoring system for sensitive activities in view of preventing the commitment or even the attempted commitment of offences envisaged by Leg. Dec. 231/2001.

The Model of ZHERMACK S.p.A. consists of the following documents:

General section

Special Part A: offenses against the Public Administration

Special Section B: IT offences and illegal data processing

Special Part C: offenses against individual personality

Special Part D: offences of manslaughter, severe or very severe lesions committed with violation of the rules on protection of health and safety at work

Special Part E: environmental offences

Special Part F: offenses entailing fake instruments or signs of recognition and offenses against the industry and trade

Special Part G: offenses relating to copyright violation

All Third Parties may inquire for information on the Model of ZHERMACK SpA to odv@zhermack.com or by mail at the following address: SURVEILLANCE ORGAN c / o ZHERMACK SpA, Via Bovazecchino 100, 45021 Badia Polesine (Rovigo), Italy.